Privacy Policy
Effective Date: March 2026 Governed by: UK GDPR & Data Protection Act 2018
We collect only the information we need to match clients with closers and run our placement service. We never sell your data. We never share it with anyone outside of what is necessary to operate the business. You can ask us to see, correct, or delete your data at any time by emailing support@be1hundred.com. We respond to all data requests within 30 days.
1. WHO WE ARE
be1hundred ("we", "us", "our") is a boutique high-ticket sales closer placement agency operating in the United Kingdom and across English-speaking and DACH (Germany, Austria, Switzerland) markets.
Name: be1hundred
Website: be1hundred.com
Contact email: support@be1hundred.com
Data controller: be1hundred
Governing law: UK GDPR and the Data Protection Act 2018
For the purposes of UK data protection law, be1hundred is the data controller in respect of personal data collected through this website and our placement services.
2. WHAT PERSONAL DATA WE COLLECT
We collect personal data in two contexts: from businesses applying to work with us as clients, and from sales closers applying to join our placement roster. We only collect data that is necessary for these purposes.
2.1 Data Collected from Business Clients
Full name (collected via application form) to identify the contact person. Company name and website (collected via application form ) to assess business eligibility. Business email address (collected via application form) to communicate with you about your application and placement. Industry and revenue information (collected via application form) to assess whether your business qualifies for our service. Offer price point and lead volume (collected via application form) to match you with an appropriately tiered closer. Timeline and availability (collected via application form) to schedule discovery calls and plan placements. Communications (collected via email, WhatsApp, and video calls) to manage your placement engagement.
2.2 Data Collected from Closer Applicants
Full name (collected via application form) to identify you on our roster. Email address (collected via application form) to communicate about your application and placements. Current or most recent role (collected via application form) to assess your closing experience. Self-reported closed revenue figures (collected via application form) to assign you to the appropriate tier. Preferred deal sizes and industries (collected via application form) to match you with suitable client opportunities. Availability (collected via application form) to schedule interviews and placements. Loom video introduction link (collected via application form) to assess communication style and professionalism. Written answers about your background (collected via application form) to understand your experience and differentiation. Interview notes and assessment scores (collected internally by the be1hundred team) to record tier assignment decisions and placement suitability. Proof of closed revenue (if requested, provided directly by applicant) to verify tier assignment at Tier 2 and above. Communications (collected via email, WhatsApp, and video calls) to manage your placement and ongoing roster membership.
2.3 Data Collected Automatically
When you visit be1hundred.com, we automatically collect certain technical data through cookies and analytics tools, including: IP address and approximate location, browser type and device information, pages visited and time spent on site, referring website or source, and clicks on calls to action and buttons.
This data is collected via Google Analytics 4, LinkedIn Insight Tag, and Meta Pixel. It is used to understand how visitors use our website and to improve the performance of our advertising. See Section 6 for full cookie details.
3. OUR LAWFUL BASIS FOR PROCESSING
Under UK GDPR, we are required to have a lawful basis for processing your personal data. We rely on the following bases:
Processing client and closer applications — Legitimate interests. We have a legitimate interest in assessing whether applicants are suitable for our placement service.
Managing active placements — Contract. Processing is necessary to perform the placement service you have engaged us to provide.
Sending application responses and communications — Legitimate interests. We have a legitimate interest in responding to people who have contacted us and managing our business relationships.
Maintaining our closer roster and client records — Legitimate interests. We have a legitimate interest in keeping accurate records of our roster members and client relationships.
Website analytics and advertising pixels — Consent. We rely on your consent, obtained via our cookie consent banner, for placing analytics and advertising cookies.
Responding to data subject rights requests — Legal obligation. We are legally required to respond to valid requests under UK GDPR.
4. HOW WE USE YOUR PERSONAL DATA
4.1 For Business Clients
– To review and respond to your application to work with be1hundred
– To assess whether your business meets our eligibility criteria
– To schedule and conduct discovery calls
– To match you with an appropriately tiered closer from our roster
– To manage your placement engagement, including check-ins and performance reviews
– To contact you about your account, active placements, and any follow-up services – To maintain records of our business relationship for legal and operational purposes
4.2 For Closer Applicants
– To review and respond to your application to join the be1hundred roster
– To assess your experience, communication, and suitability for placement
– To assign you to the appropriate tier based on your verified track record
– To match you with suitable client opportunities
– To facilitate introduction calls between you and prospective clients
– To manage your active placements and ongoing roster membership
– To contact you about placement opportunities, tier reviews, and promotions
4.3 For All Website Visitors
– To understand how our website is used and improve its performance
– To measure the effectiveness of our advertising campaigns
– To build retargeting audiences for LinkedIn and Meta advertising (with consent)
5. WHO WE SHARE YOUR DATA WITH
We do not sell your personal data. We do not share it with third parties for their own marketing purposes. We share data only in the following limited circumstances:
Prospective client (regarding a closer) — We share the closer's name, tier, and placement brief (to facilitate the three-way intro call and placement process) shared only once a client agreement is in place and a non-circumvention clause applies.
Prospective closer (regarding a client) — We share the client's business name, offer type, deal size, and pipeline overview (to brief the closer before the intro call) shared only once both parties have expressed mutual interest.
Google Analytics — We share anonymised website usage data for analytics and website improvement. No personally identifiable data is shared.
Meta (Facebook/Instagram) — We share Pixel data from website visits (with your consent) for advertising retargeting and lookalike audiences, processed under Meta's data processing terms.
Professional advisors — We share data as necessary for legal, financial, or compliance purposes, subject to confidentiality obligations.
Law enforcement or regulatory bodies — We share data only where legally required to do so.
6. COOKIES & TRACKING TECHNOLOGIES
Our website uses cookies and similar tracking technologies. A cookie is a small text file placed on your device when you visit a website.
Strictly necessary cookies — provided by Wix (our website platform) — required for the website to function, including session management and form security. No consent required.
Analytics cookies — provided by Google Analytics 4 — used to understand how visitors use the site, including page views, traffic sources, and behaviour. Requires consent.
Advertising/retargeting cookies — provided by Meta Pixel — used to build retargeting audiences and measure ad effectiveness on Facebook and Instagram. Requires consent.
Advertising/retargeting cookies — provided by LinkedIn Insight Tag — used to build retargeting audiences and measure ad effectiveness on LinkedIn. Requires consent.
You can manage your cookie preferences at any time via the cookie consent banner on our website, or by adjusting your browser settings. Withdrawing consent for analytics and advertising cookies will not affect your ability to use the website.
7. HOW LONG WE KEEP YOUR DATA
We retain personal data only for as long as is necessary for the purposes for which it was collected, or as required by law.
Unsuccessful client applications — retained for 12 months from date of application — to allow reapplication and maintain a record of prior contact.
Unsuccessful closer applications — retained for 12 months from date of application — to allow reapplication. We encourage declined applicants to reapply after 90 days.
Active client records — retained for the duration of engagement plus 3 years — for legal, financial, and dispute resolution purposes.
Active closer roster records — retained for the duration of roster membership plus 3 years — for legal, financial, and dispute resolution purposes.
Placement records (both sides) — retained for 6 years from date of placement — to comply with UK contract law limitation periods.
Financial records (invoices and payments) — retained for 6 years — as required by HMRC and UK accounting regulations.
Website analytics data — retained for 26 months (Google Analytics default) — anonymised after this period.
Email and WhatsApp communications — retained for 3 years from last contact — to maintain a record of business communications.
When data is no longer required, we delete it securely from all systems. If you would like us to delete your data earlier, please contact us at support@be1hundred.com. We will action all deletion requests unless we are legally required to retain the data.
8. YOUR RIGHTS UNDER UK GDPR
As a UK data subject, you have the following rights in relation to your personal data. We will respond to all valid requests within 30 days.
Right of access — You can request a copy of all personal data we hold about you (a Subject Access Request). Email support@be1hundred.com with the subject line "SAR Request".
Right to rectification — You can ask us to correct any inaccurate or incomplete data we hold about you. Email support@be1hundred.com.
Right to erasure — You can ask us to delete your personal data. We will comply unless we have a legal obligation to retain it. Email support@be1hundred.com with the subject line "Erasure Request".
Right to restrict processing — You can ask us to pause processing your data in certain circumstances, for example while you contest its accuracy. Email support@be1hundred.com.
Right to data portability — You can request your data in a structured, machine-readable format to transfer to another service. Email support@be1hundred.com.
Right to object — You can object to processing based on legitimate interests. We will stop unless we can demonstrate compelling legitimate grounds. Email support@be1hundred.com.
Right to withdraw consent — Where processing is based on consent (for example, cookies), you can withdraw consent at any time without affecting prior processing. Use the cookie banner on the site or email support@be1hundred.com.
Right to complain — If you believe we have handled your data unlawfully, you have the right to lodge a complaint with the Information Commissioner's Office (ICO) at ico.org.uk/make-a-complaint or by calling 0303 123 1113.
9. INTERNATIONAL DATA TRANSFERS
be1hundred operates primarily in the United Kingdom. Because we serve clients and closers across DACH markets (Germany, Austria, Switzerland) and other countries, some personal data may be transferred internationally.
Where we transfer personal data outside the UK, we ensure appropriate safeguards are in place in accordance with UK GDPR, including transfers to countries covered by UK adequacy regulations, use of Standard Contractual Clauses where required, and reliance on processors such as Google and Meta who maintain appropriate transfer mechanisms.
The EU-UK adequacy decision means that transfers between the UK and EU/EEA countries — including Germany, Austria, and Switzerland — are permitted without additional safeguards for the duration of the adequacy decision.
10. HOW WE PROTECT YOUR DATA
We take the security of your personal data seriously and implement appropriate technical and organisational measures to protect it against unauthorised access, loss, or disclosure. These measures include:
– All application data transmitted via Wix is encrypted in transit using SSL/TLS
– Business email (Google Workspace) secured with two-factor authentication
– Notion databases used for internal tracking are access-restricted to authorised team members only
– No personal data stored in unsecured formats such as unprotected spreadsheets shared externally
– WhatsApp Business communications limited to active placement clients only
– Team members trained on data handling obligations before accessing any personal data
In the event of a personal data breach likely to result in a risk to your rights and freedoms, we will notify the ICO within 72 hours of becoming aware of the breach, and will notify affected individuals without undue delay where the breach is likely to result in a high risk to them.
11. THIRD-PARTY LINKS
Our website may contain links to third-party websites, including LinkedIn and social media platforms. This Privacy Policy applies only to be1hundred.com. We are not responsible for the privacy practices of third-party websites and encourage you to review their privacy policies before providing any personal data.
12. CHILDREN'S DATA
Our website and services are directed at business professionals and are not intended for use by individuals under the age of 18. We do not knowingly collect personal data from children. If you believe we have inadvertently collected data from a child, please contact us at support@be1hundred.com and we will delete it immediately.
13. CHANGES TO THIS PRIVACY POLICY
We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or the way we operate. When we make material changes, we will update the effective date at the top of this policy and, where appropriate, notify active clients and roster members by email. Continued use of our website or services after any changes constitutes acceptance of the updated policy.
14. CONTACT US
If you have any questions about this Privacy Policy, wish to exercise any of your rights, or want to make a complaint about how we have handled your personal data, please contact us:
Email: support@be1hundred.com Website: be1hundred.com Response time: We aim to respond to all data-related enquiries within 30 days. ICO (if unresolved): ico.org.uk/make-a-complaint — 0303 123 1113
We take all privacy concerns seriously. If you contact us with a complaint or concern, we will acknowledge your message within 5 business days and work to resolve it as quickly as possible.